IR 05000353/1987017
| ML20196C885 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/10/1988 |
| From: | Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196C781 | List: |
| References | |
| 50-353-87-17, IEB-78-12, IEB-80-08, IEB-80-8, IEC-77-09, IEC-77-9, IEC-80-05, IEC-80-21, IEC-80-5, NUDOCS 8802160268 | |
| Download: ML20196C885 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 87-17 Docket No. 50-353 License No. CPPR *407 Category A/B Licensee:. Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 2 Inspection Conducted: December 21, 1987 to January 24, 1988 Inspectors:
R. A. Gramm, Senior Resident Inspector H. J. Kaplan, Senior Reactor Engineer 7/lf!TT Reviewed by:
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OM J./ H. Williams, Project Engineer Oa'te /
RQctorProjectsSection2A Approved by:
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C. Linvil%,' Chief
'Da t'e tor Projects Section Inspection Summary:
Report for Inspection Conducted December 21, 1987 to January 24, 1988 (Report No. 50-353/87-17)
Area Inspected:
Routine inspection by the resident inspector of work activities, procedures, and records relative to HVAC duct and supports, reactor pressure vessel cleanliness, system turnover, preoperational test procedure review, preservice examination program, Bechtel quality assurance, blue tag testing, and assurance of quality.
The inspectors reviewed licensee action on previously identified items and performed plant inspection tours.
The inspection involved 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> by the inspectors.
Results:
No violations were identified.
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DETAILS 1.0 Summary The inspectors reviewed 16 NRC open items for closure and returned four to the licensee for corrective action implementation or further investi-gation.
Most significantly, Construction Deficiency Report 83-00-06 was inappropriately presented for closure as Bechtel engineering investigations, resulting from an event at another facility, were being performed on the containment motor operated isolation valve design (section 3 and 4).
Bechtel QC personnel were accompanied during final inspection of duct components (section 5).
The Reactor Pressure vessel cleanliness controls were reviewed (section 6).
The conduct of system turnover walkdowns were monitored for the safeguard instrument AC and 440V load centers (section 7). Two preoperational test procedures, for the drywell HVAC and reactor pressure vessel hydrostatic test, were satisfactorily reviewed (section 8). The conduct of a preservice examin3 tion and examination data were reviewed (section 9).
The Bechtel QA files for recent audits and selected finding reports were reviewed (section 10).
The performance of preliminary Blue Tag testing was witnessed (section 11).
In section 12, Assurance of Quality, the NRC concerrs involving motor operated isolation valves and
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reactor pressure vessel cleanliness controls are further examined.
2.0 Plant Inspection Tours The inspector observed in progress work activities, completed work, 7.nd plant status in several areas during inspection tours. Work was examined for defects and compliance with regulatory and licensee requirements.
Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation.
The inspector interviewed craft supervision, craft and quality control personnel in the work areas.
Observations are noted below:
The inspector observed the installation of high voltage terminations
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for cable 2AG501BB.
Bechtel QC performed a 100*. ir.spection of the inprocess termination activity.
The Raychem termination kit was installed in accordance with the manufacturer's requirements.
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The inspector witnessed the initial energization of 440V load center D234. The equipment was energized without problems.
No violations were identified.
3.0 Licensee Action on Previously Identified Items a.
(Closed) Construction Deficiency Report (80-00-01): Electrical raceway separation deficiencies.
The following documents were reviewed by the inspector:
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PECO Significant Deficiency Report 9
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Management Corrective Action Report (MCAR) 20
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t The licensee had identified numerous instances where the minimum spatial separation requirements between redundant Class IE raceway, conduit and junction box installations had not been maintained.
The licensee attributed the problem to craft misunderstanding of the definition of redundant equipment and that QC only performed in process surveillance inspections far separation.
The licensee instituted the. folic #ing corrective actions:
Drawing E-1406 was revised to provide clarification on the
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Class IE separation requirements.
QC inspection plans were revised to include a final acceptance
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inspection attribute for separation.
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Training was provided to QC personnel regarding the required-
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separation criteria.
Exposed Class IE raceways were re-inspected to the revised
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separation criteria.
Nonconformance reports were issued as necessary.
The following nonconformance reports resulting from the reinspection were reviewed in conjunction with the noted engineering disposition:
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NCR problem Dispositica 3871 Junction boxes with less than 1" Rework to provide separation l separation 3872 2 Raceways do not provide 1"
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separation 1" separation
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3873 14 Raceways do not provide 1" Rework to provide separation 1" separation 3874 6 Junction boxes do not provide 1" Rework to provide separation 1" separation 3898 2 Junction boxes do not provide 1" Rework to provide
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separation 1" separation 3900 2 Junction boxes do not provide 1" Rework to provide separation 1" separation
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3909 Lighting conduit does not provide Rework to provide
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required separation required
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separation
4005 4 Junction boxes do not provide 1" Rework to prov-;de
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separation 1" separation
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4006 Conduit, cable tray and junction Rework to provide
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boxes do not provide required required
separation separation 4007 Conduit, cable tray and junction Rework to provide
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boxes do not provide required required
separation separation
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4008 4 Junction boxes do not provide Rework to provide 1" separation required separation 4009 Cable tray does not provide required Rework, provide separation necessary barrier 4010 Conduit and junction boxes do not Rework to provide provide required separation required separation 4011 Raceway does not provide required Rework raceway to separation provide required separatiou 4012 2 Junction boxes @ not provide 1" Rework to provide separation 1" separation 4013 Raceway does not provide required Rework to provide separation required
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seoaration 4014 Conduit and cable tray do not Rework to provide provide required separation required separation 4015 2 Junction boxes do not provide 1" Rework to provide separation 1" sept. ration 4016 Raceway and junction boxes do not Rework to provide provide required separation required separation The current site program to control electrical separation has teen reviewed and documented in NRC Inspection Reports 87-14 ar.d 86-15.
The site separation criteria is less stringent than Regulatory Guide 1.75 criteria.
The site pronram and the associated tests and analysis to support the reduced separation criteria have been reviewed and accepted by the NRC Office of Nuclear Reactor Regulation.
The Bechtel QC inspection plans for inspection of separation criteria have been reviewed.
Final acceptance of separation will be performed during the facility turnover stage which requires a detailed QC inspection of the cable routings, During cable pull in process inspections a QC verification is performed to assure that gross separation violations do not occur such as mixing of Class 1E and non-1E cables.
Based upon the licensee resolution of the identified deficiencies and changes made to the site separation control program, this item is closed, b.
(Closed) Construction Deficiency Report (80-00-08):
ASME fasteners procured from manufacturer lacking quality certification.
Nonconformance Reports 4748, 4224, 4581, 4221, 4225, 4582, and 4610 documented that all fasteners furnished by REC Corporation were returntd because of the ' failure to meet ASME Section III-NA3700 QA requirements.
This item is close.o i
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(0 pen) Construction Deficiency (80-00-10):
Separation of electrical
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wiring within the control room complex.
The inspector reviewed Bechtel QC Instruction RW-1.10 and drawing E-1412. The internal
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I wire separation and barrier requirements were found consistent with-
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FSAR section 8.1.6.1.14.b.9.
This item will remain open pending
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completion of the panel separation verification by Bechtel.
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- (Closed) Construction Deficiency Report (80-00-12):
Improper i
i welding of safe ends to reactor nozzle.
The inspector reviewed the
problem description and the licensee response to the NRC dated April 1981.
The licensee determined that although the welding was not performed in accordance the welding procedure, no detrimental effects occurred as verified by final weld acceptance including visual, liquid penetrant, radiography and ultrasonic examinations of
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the welds. The inspector requested the licensee to determine if the
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wash passes, which were made without the addition filler metal, were liquid penetrant inspected. The licensee responded that no liquid penetrant inspection had been performed on the intermediate weld passes.
The inspector noted that wash passing of previously deposited weld beads, as was done in this case, is generally less
susceptible to cracking than base metal subjected to wash passing.
Based upon the satisfactory examination of the completed weld in i
accordance with code requirements and the General Electric review of
this situation, this item is considered closed, i
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(Open) Construction Deficiency Report (83-00-06): Motor operated
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containment isciation valves.
In 1983 the licensee identified a
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i phenomena where the 480 volt-circuit breaker which feeds the valve
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operator would trip on high current, This would occur when the j
valve was being opened and a simulted containment isolation signal would cause an instantaneous reversal ef the valve. This would trip l
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the power feed circuit breaker.
The licensee determined that his
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was not a significant problem because ASM6 Section XI valve testing
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would be done with one valve at a time and the redundant isolation
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valve would perform the containment isolation function in the event i
the circuit breaker tripped on the tested valve.
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The inspector reviewed numerous surveillance test procedures and
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confirmed that precautions exist that would allow only single valve
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testing.
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The inspector additionally reviewed FSAR Section 6.2.4, Regulatory
Guide 1.41 and ANS 56.2 regarding containment isolation. The valve
operator logic provides for an override of the thermal trip when the
operator receives an isolation signal. The inspector questioned Bechtel electrical engineering as to the design basis for the motor
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i operated valves (MOYS) and to provide any additionr.1 analysis regnrding the situation noted in 1983.
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The inspector was informed that Quality Action Request QAR-F-608 addressed incidents of unwanted Limitorque MOV travel reversals.
Bechtel had also issued Problem Investigation Report G-87-19-EQ for all projects to evaluate the breaker setting-for motor operated valves.
The current design guidance is that the instantaneous breaker settings should be twice the locked rotor valve... Valves which undergo instaneous travel reversals should be reviewed for proper breaker setting, valve qualification for instantaneous reversal, and for the necessity of adding a time. delay to avoid instantaneous reversal.
The inspector asked the licensee to confirm the electrical circuit design settings for the containment MOVS.
This item remains open pending licensee resolution of the Bechtel findings, f.
(Open) Construction Deficiency Report (84-00-03):
Engagement of Agastat relay sockets. Pending completion of the Blue Tag testing that will verify the proper relay socket engagement, this item remains open.
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(Closed) Violation (87-02-03):
Verification of closure weld cold pull deflections.
The inspactor reviewed Inprocess Rework Notice (IPRN) P-7147 and small bore pipe redlines 6 and 7 for drawing DCA-213-E3.
Field weld 201 was cut out, the reactor vessel drain piping closure deflections were verified acceptable and the piping was reinstalled. Bechtel QC and engineering reviewed other small bore piping and found seven other welds for which QC had not per-formed the requisite closure verification as documented on NCR 11737.
The licensee reviewed available records, interviewed cognizant field engineers, and stroked several valves to ensure that no excessive stresses existed in the piping system.
Field engineer records for field verified closures demonstrated the acceptability of foJr of the questionable welds. A Field Change Request was issued to clarify those instances of closure welds for which QC verification would no longer be required. Bechtel revised procedure FM-15 for definition of the pipe closure requirements.
QC inspection plan P-1.10 was revised to reflect the new closure criteria and training was provided to QC personnel.
The inspector was informed that PECO QA has performed several audits of the pipe closure activities with satisf actory results. This item is closed, h;
(Closed) Unresolved Item (87-08-01):
Heat exchanger welding records.
The inspector noted several errors in the calculation of the tensile strength data for carbon steel Procedure Qualification Record (PQR) 106 and PQR 103.
These PQR's were identified as qualification records for Welding Procedures (WPS) 106 and 103 which were used in the fabrication of two Residual Heat Removal (RHR) heat exchangers. Also, Welding Procedure 9008, although properly-qualified, used non-ASME terminology for the base material specification. The licensee requested General Electric (GE) to
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investigate these discrepancie's even though the manufacturer, Delta-Southern, is no longer in business. The inspector reviewed GE's
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summary response. GE stated that the essential and non-essential variables for PQRs 106 and 103 were consistent with industry practice. Because the manufacturer is no longer in business, no additional evidence was resurrected by GE to support the PQRs.
The licensee additionally conducted hardness tests in the presence of-
the inspector using a calibrated Equotip hardness tester on nozzle-N1-1 for heat exchangers 2AE205 and 2BE205. These welds were identified by Delta Southern as having been welded and qualified in
accordance with WPS/PQR106. The average hardness values representing weld metal (E7018) parent metal (SA516-70) and the heat affected zone ranged between Rockwell 13 86.2 and 95.4.
These valves are consistent with the strength levels of the materials used in the fabrication of the subject vessels. With regard to PQR 103, GE also acknowledged
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the discrepancy, but noted that WPS 103 was only used for welding temporary hydrotest covers on several nozzles. With regard to WPS 9008 GE stated that the base material should have been SA516-70,
and that it was intended as a technique sheet for weld repairs.
Based upon the GE investigation and licensee hardness testing this item is glosed.
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(0 pen) Violation (87-14-01): Quality requirements for diesel generator auxiliary piping. By letter dated January 6, 1988, Philadelphia Electric Company responded to the violation with planned corrective and preventative actions.
The licensee actions will be reviewed during a future inspection, this ite:n remains open.
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(Closed) Unresolved Item (87-14-03):
Trash collection bucket impact on Class 1E raceway.
Bechtel Quality Control reinspected the safety i
related cabit tray and supports at elevation 217 and 253 in Reactor Building area 10.
No damage was identified by the inspection as i
i documented in Field Inspection Report E14060068. The construction personnel that handle the trash buckets were reinstructed on the
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proper rigging methods to be used.
This item is closed, i
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(Closed) Unresolved Item (87-15-01): Conduct of wetwell turnover walkdown.
The licensee had subdivided the wetwell into several partial turnovers based upon component elevation. A final turnover walkdown was performed to ensure that no commodities had suffered'
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damage during the staging removal.
The staging removal was l
coordinated with the conduct of coating activities within the J
drywell. The inspector monitored the wetwell turnover process and I
observed the conduct of several walkdowns.
Based upon the
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satisfactory performance of the licensee's efforts this item is
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closed.
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4.0 Licensee Action on IE Bulletins and Circulars The inspector reviewed licensee records related to the IE Bulletins and-Circulars identified below to verify that; the IE Bulletin or Circular was received and reviewed for applicability; a written response was pr.vided if required; and the corrective action.taken was adequate.
The following IE Bulletins and Circulars were reviewed:
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(Closed) IE Circular 77-09:
Improper Fuse Coordination in BWR Standby Liquid Control System Control Circuits.
The Limerick explosive valves receive electrical power through a 20 AMP breaker in a Y panel.
The inspector reviewed drawings 8031-M-1-C41-1040-E-009
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and 010 and found a 2 AMP fuse in series with the breaker.
PECO and Bechtel electrical engineering reviewed the fuse coordination and-found no problems.
This item is closed.
b.
(Closed) IE Bulletin 78-12: Atypical Weld Material in Reactor
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Pressure Vessel Welds.
The inspector reviewed the licensee's response to the subject bulletin involving atypical weld material in i
the Limerick 1 and 2 reactor vessels.
The licensee provided a letter that had been sent to NRC in May 1979 which stated that Chicago Bridge and Iron (CBI), the vessel manufacturer, had completed a search of weld records and found no deviations in Limerick No. 1 and 2 reactor vessels.
The CBI report was submitted to NRC on April 24, l
1981.
Based upon the review performed by CBI, this item is closed.
c.
(0 pen) IE Circular 80-05:
Emergency Diesel-Generator Lubricating 011 Addition and Onsite Supply.
Pending completion of licensed operator training cycle 6, covering diesel auxiliary systems, and the designation of emergency-use-only lubrication oil barrels for
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Unit 2, this item remains open.
d.
(Closed) IE Bulletin 80-08:
Examination of containment liner l
The inspector reviewed the licensee's respense
to the subiect bulletin that stated all flued head to containment
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butt welds were radiographed.
The inspector reviewed the inspection records for six joints and verified that radiography had been
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performed.
This item is closed.
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(Closed) IE Circular 80-21:
Regulation of refueling activities.
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inspector reviewed the following documents:
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surveillance test ST-6-107-630-1, "Core Alteration Testing"
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i surveillance test ST-6-107-591-1, "Daily Surveillante
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Log-OPCONs 4&5" j
procedure FH-602, "Qualification of Refueling Platform
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Operators" The surveillance procedures verify that prior to and during core alterations that direct communications exist between the refuel t
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i floor and control room personnel.
The inspector was informed that plant procedure A-7 requires -a senior licensed operator (SLO) on the refueling bridge and a licensed operator (LO) in the control room to observe the Scurce Range Monitors (SRMs) during the refueling operations.
Limerick operators attend special training and are qualified to perform refueling platform operations.
This item is closed.
5.0 HVAC Duct-and Supports
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The following documents were *eviewed by the inspector:
Bechtel specification M-63A-2, "HVAC Installation C'. ass 1"
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Bechtel QC Instructions
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M-4.10-2, "Installation of HVAC Supports" M-4.20-2, "Installation of HVAC Ductwork and Components" Limerick Safety Evaluation Report Section 9.4
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FSAR section 9.4
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table 9.4-4
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The FSAR commitments for duct installation and inspection criteria
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were found properly translated into the engineering specification.
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b.
Tne inspector accompanied Bechtel QC personnel during the QC
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inspection of duct support H1161-01-H037 on the drywell purge air
exhaust duct.
The associated design drawings (drawing M-1161,
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C-1364 details 8 and 8A, and Field Change Request MV-918) were
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reviewed. The QC inspector was observed during the inspection of
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hanger location, weld si:e and quality, hanger configuration, member size and clearance from adjacent items.
The inspector had no
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The inspector additionally accompanied Bechtel QC personnel during c.
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the final QC inspection of duct piece 108A depicted on Schneider
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fabrication drawing M1177-1-SSM.
The duct piece was examined for r
weld quality, configuration, sheet metal thickness, flange bend
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radius and touch up coating of the weld.
The following documents were reviewed during the course of the inspection: drawing C-1354-2, FCR MV393, FCR MV 1324 and drawing M1177. The inspector had no concerns.
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The inspector accompanied Bechtel QC personnel during the final
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inspection of a four way diffuser SR-502-52. The diffuser was
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i inspected for configuration, location, fastener installation, damage
and clearance from other plant items.
The insptetor reviewed the
associated design drawings: M-1175, C-1354-2 and M-1164. The
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inspector had no concerns.
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6.0 Reactor Pressare Vessel Cleanliness The inspector examined the following documents that pertain to the cleanliness controls for the Reactor Pressure Vessel (RPV):
GE Specifications
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22A4111, "General Instructions for Reactor Assembly" (Section l
22)
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22A2537, "Field Cleaning and Cleanliness of Nuclear Power Plant Components" 22A4202, "Reactor Assembly, Welding, Cleaning, Examination and Storage" Bechtel Construction Procedure CP-C-4, "Jobsite Housekeeping
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and Cleanliness Contro *
The General Electric specifications include provisions for:
proper cleanliness zone classification for the RPV; sealing of RPV penetrations; protective covering for the RPV; no eating, smoking, or drinking in the RPV; control of personnel accees; and use of shoe covers and overalls.
These requirements are invoked before the RPV flush is performed.
After the flush is conducted the following supplementary requirements are invoked:
use of lanyards on hand tools; implementation of a tool inventory record; and prohibition on loose articles within the RPV.
The RPV cleanliness control responsibility had recently been assumed by Bechtel upon the completion of the RPV internals work performed prior to the hydrostatic test.
The Bechtel procedure did not incorporate certain elements of the GE specifications such as use of overalls and maintaining the top of the vessel covered.
The inspector was informed that the licensee had recognized the procedural inconsistencies and was revising CP-C-4 accordingly (PECO Finding 2G-709).
The inspector reviewed the Bechtel Long Term Maintenance records for the RPV. Quality control had performed several i
visual inspections since Bechtel had assumed cleanliness responsibility.
i On December 1, 1987, Nonconformance Report 12729 was issued to document the existance of particulates inside the RPV, that top openings were not covered and that the proper cleanliness zone had not been posted at the RPV. On December 10, 1987, a Maintenance Action Item was issued to close l
the holes around the top platform. On December 31, 1987, the inspector observed that the items addressed by the NCR had not yet been addressed.
The Bechtel personnel were awaiting GE disposition to a Field Deviation and Disposition Report prior to correcting the identified concerns.
The inspector discussed the need to reduce the RPV internals exposure to contamination with licensee management. Work was promptly initiated by Bechtel to close the RPV top cover holes, to vacuum out the RPV nozzles and to post the proper cleanliness zone for the RPV. General Electric determined that the amount and types of particulates that had accumulated in the RPV would be removed during the flushing process.
Based upon the licensee actions that were taken, the inspector had no further concerns.
No violations were identified.
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7.0- System Turnover
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a.
The inspector reviewed the following' documents that describe-the i
construction turnover process:
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' Construction Precedure CP-T-1, "System / Partial Turnover"
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Quality Control Special Project Provision G-10.1,
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"C<mponent/ System Turnover"-
l The turnover process includes a final walkdown verification that the completed installations meet the specified quality requirements and
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that the components have not suffered any damage since the previous
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quality control inspections were performed. The walkdown teams are comprised of quality control, construction and system turnover engineers. As discussed below, the inspector accompanied licensee personnel ouring the conduct of two system turnovers,
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The inspector monitored the construction turnover walkdown for j
system 17A, Instrument AC power and System SA, Safeguard 440V Load
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Centers.
The walkdown team was composed of personnel.from PECO
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construction Bechtel construction, Bechtel QA and QC, and Bechtel
s system turnover group.
The walkdown scope included the following safety related equipment:
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440V Motor Control 120V
Center Breaker Cubicle Transformer In strument Panel i
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20B211-11A 20X106 20Y101
208212-10A 20X107 20Y102 l
20B223-1A 20X108 20Y103 i
20B224-1A 20X109 20Y104-20B213-8A 20X281 20Y206
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20B214-8A 20X282 20Y207 208217-3A 20X283 20Y163 20B218-3A 20X284 20Y164 SYSTEM 5A i
440V Load Center Transformer 20-B201 20X201 20-B202 20X202
l 20-8203 20X203 20-8204 20X204
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The inspector observed the conduct of the licensee's walkdown.
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inspector examined the completed electrical installations for damage, for i
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proper equipment identification, for component configuration, for proper electrical cable termination and identification, and for the removal of-breakers under the purview of startup personnel.
The following documents were reviewed by the inspector:
turnover component indices; startup punchlist for system 17A; Bechtel drawings E-16, E-29, E-26'and E-31; and.
FSAR section 8.3.1.1.2.10.
The inspector had no concerns.
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No violations were identified.
8.0 Preoperational Test procedure Review a.
The inspector reviewed the following documents that pertain to _the drywell chilled water heating, ventilating and air conditioning system:
Preoperational test procedure 2P60-1, Rev.1, "Drywell Chilled
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i Water HVAC System - Startup System 60" Limerick FSAR sections 9.3 10.1, 9.4.5.2, 7.3.16.2
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table 9.2-M, 9,4-10 figure 9.2.", 0.4-7, 9.4-8, 7.3-13 Limerick Unit 1 Technical Specification Section 3.6.6.2 and
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l table 3.6.3-1
Limerick SER Sections 6.2.5, 9.2.7.4 i
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Logic Diagram M-77F0
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l Piping and Instrument Diagram M-77 Sheet 2
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Electrical Schematic Diagrams E-469, E-476 and E-649
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The drywell unit coolers perform a safety related function for post-accident mixing of the drywell atmosphere. The chilled water system is not safety related.
The test procedure was reviewed with respect to the administrative requirements contained in Startup Administrative Manual AD8.1.P to verify: proper format; defined test objectives; proper test prerequisites; initial conditions; test data recording requirements; system restoration; and correct acceptance criteria.
The portions of the test that pertain to manual and automatic operation of drywell unit cooler 2AV212 were reviewed. The test procedure steps and acceptance criteria were found consistent with the Bechtel design documents.
The inspector noted that FSAR figure 7.3-13 defined the time delay set point for relays KS-77-105A and KS-77-107A as 30 and 20 seconds respectively.
The Bechtel electrical schematics identified the time delays as 40 and.30 seconds for the relays.
The licensee stated a Licensing Document Change Notice would be written to correct the FSAR. The Limerick Unit 1 Technical Specifications Section 3.6.6.2 defined the operability of the four drywell unit coolers as the ability to manually start the units from the control room and run
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'them for 25 minutes.
Theinspectohwasinformeddhatasurveillance test was written to verify this operability criteria.
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The inspector was informed that Technical Test Procedure TT1.10 for flow balancing had not yet been approved for use.
The verification that the drywell cooling system can maintain acceptable' ambient atr
and concrete temperature conditiout will be verified during the conduct of startup prot.edure 32. ^
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T - inspector reviewed the following documents that relattto the
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conduct of the ASME Section III hydrostatic test of the4.eactor Pressure Vessel (RPV):
s Limerick FSAR section 5.3.2
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taole 5.3-2/i
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Limerick SER sact' ion 5.3.2 s?',
Linarick 1 Technical Specifications
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ASME 0ivision 1 Section XIdWA-5000-
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ASME Division 1,Section III-NB6dGO
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Bechtel procedure VM-19, "RP (Cc & $ drostatic Test"
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Bechtel specitR ation P323
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General Electric Specificatiend '
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22A4111, "Reactor Assembly In'struct' ions"
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22A4202, "Reactor Assembly, WM ding", Cieaning, Examination and Storage"
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22A2284, Nield Erection of Reactor Reciralation Piping" 22A2749, "Cleaning of Pipin't,un:1.Equipent".
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22A2513,' "Field Eraction.. of;Pr' mary Steam. Piping System"'
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General Electric Field Deviktjon and Disposition Reguest HH2-8464, Rev. O and j
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Bechtel Construction Prkedu.re M_-2, "Pressure Testing of Piping and Components"
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The inspector verified the site procedure for the conduct of the RPV hydrostatic test will provide proper direction for the.Jollowing activities:
valve lineup, temporary jumper installations, vessel heatup prior to head tensioning, vessel pressurization to test.and inspection pressures, test, pressure ho]d duration gprovision for overpressure protection, pr0 vision for thermocoupl'e'40kitoring of RPV shell temperature, control of water chemistry,'a'nd verification of hanger installations.
The procedure had been reviewij and approved by Bechtel construction and quality groups, PECO, construction, operations and quality groups, the AN1 and ANII, General Electric and the PA state inspector.
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The inspector additionally reviewed the following Pipina'ar,d Instrument Diagrams (P& ids) and verified the accuracy of portions of the valve lineup:
M-40, M-41, M-42, M-48 and M-49.
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The inspector' asked the licensee:whether 'the vessel has been previously filled with TSP inhibited. water and;to provide the -
procedure that' Bechtel will utilize during:the RPV head installation.
The licensee stated the head installation procedure was in dr,ft form-and that the vessel had been filled with TSP inhibited water as.
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documented by Chicago Bridge and Iron Company documentation dated March 22, 1977.
No violations we're identified.
9.0 traservice Examination' Program a.
The following documents.were reviewed by.the inspector that relate to the Preservice Inspection Program:
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ASME Section XI, IVB-2200, "Preservice Exanination"
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Limerick-Preservice Inspection Program, Res. 1 (Bechtel Specification P-504)
FSAR Section 5.2.4
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Bechtel specifications P-301-2, "Fabrication and Installation of Piping" P-505, "Preservice Examination Plan" P-503A, "Automatic / Manual Ultrasonic Examination. Services" Construction procedure CP-W-4, "Preservice Ihspection of
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Nuclear Piping Systems" The procedures were reviewed with respect to 3xamination personnel qualifications, nondestructive examination performance, weld surface preparation and marking, and examination acceptance standards.
The inspector had no concerns, b.
The inspector witnessed the performance of a manual ultrasonic examination on field weld 60 isometric DBA-207-1 of the Reactor Core Isolation Cooling (RCIC) system.
The weld surface had been properly prepared for the examination.
The equipment calibration was
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observed and the construction of the Distance Amplitude Curve was checked.
The transducer scanning speed, sound beam overlap, transducer frequency and examined material surface temperature were satisfactory.
The examination identified several acceptable indications that were recorded on the data report.
The examination was also witnessed by a PECO QA representative and the ANII.
The t
inspector had no concerns.
c.
The personnel qualification and certification records were reviewed for one of the nondestructive examinaticn test personnel that performed the ultrasonic examination on (1*ld weld 60 discussed above. The records were found satisfactory.
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Preservice_ examination data packages were reviewed for the following welds:
Isometric DCA-419-1-1 shop weld'l
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Isometric'DCA-419-1 field weld.2'
The data packages included liquid penetrant examination reports; wall thickness profile sheets; General Electric "Smart UT"' system calibration data sheets; automati: UT' examination data sheets;.and weld data cards.
The inspector determined through review of the Bechtel specifications that the appropriate preservice examinations had been performed.
The inspector reviewed tne following PEC0 QA preservice examination program audits 2P-513 and 2P-517.
The associated audit checklists were reviewed.
The audits' had found no unsatisfactory conditions.
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t No violations were identified.
10.0 Bechtel Quality Assurance a.
The inspector reviewed the following audit reports that had been performed by Bechtel Quality Assurance:
Audit Date Performed Area Audited PFA-880 10/27-11/4/87 Small piping PFA-881 11/2-11/13/87 Safety analysis report compliance P FA-883 11/9-11/10/87 Project Engineering Drawings PFA-884 10/16-11/5/87 Pipe support in process control PFA-887 11/11-11/23/87 Equipment substitution, transfers and replacement The associated audit checklists, data collection sheets, and audit findings were reviewed.
The audit scope had covered hardware and software aspects of site work activities.
The audit checklists were comprehensive and the data collection sheets were well organized.
The inspector had no concerns, b.
The inspector reviewed Quality Action Request (QAR) F-593 regarding problems with small pipe threaded joints.
Bechtel Project Engineering evaluated the two inch and smaller ASME threaded connections that lacked seal welds.
Based upon the lines involved, the piping configuration and system purpose, project engineering concluded that the_ installation problems would not adversely affect the safe plant operation.
Bechtel revised the applicable piping specifications to clarify the seal welding requirements.
Project personnel were retrained to the new.eal weld criteria.
Piping isometrics were walked down to identify loc (tions that lacked seal welding and NCR's were issued to add the necessary weld metal to the joints.
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The inspector additionally reviewed QAR F-605 which documented adverse trends in raceway installation at elevation 177 in the reactor building. The raceway had been originally inspected in-February through July of 1986.. Recent cbservations had found.some discrepancies with the inspected work. -A complete walkdown reinspection was performed-of El 177 electrical raceway and other plant areas which had been originally inspected in the February through July timeframe.
Nonconformance Reports (12371, 12474, 12493, 12632 and 12671) were issued where necessary.
The Quality Control inspectors that performed the original inspections were retrained.
The corrective actions appeared satisfactory.
No violations were identified.
11.0 Blue Tag Testing a.
The inspector reviewed procedure EE11.8, "Procedure to Inspect and Test 125/250V Battery and Battery Charger" and 8031-E13-28-5BR, "C&D Stationary Battery Installation and Operating Instructions." The PEC0 procedure includes provisions for control of temporary modifications, inspection for battery damage, proper installation of battery rack ground and cell orientation, measurements of battery specific gravity, verification of electrolyte level, and performance of cell voltage readings.
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T'<t inspector reviewed in process test records regarding the blue t % testing on the safeguards batteries, chargers and distribution panels.
The inspector had no concerns.
b.
The inspector witnessed electrical cable Blue tag tests on the following 4KV cables for diesel generator A output:
2AG501A phase A, B and C 2AG50186 phase A, B and C
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The cables were megger tested at 1,000 volts for one minute duration.
The direct current over potential tests were performed on the cables at 45 KV for a five minute duration.
The insulation resistance and leakage current values were acceptable.
The test equipment utilized was properly calibrated.
PEC0 QA was present during the testing. The inspector reviewed the following documents:
PECO Test and Laboratories procedure TL-11-02006, "Cable
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Over potential Tests" Bechtel Specification E-29
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IPCEA S-68-516, section 6.27, "Voltage Tests"
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The inspector was informed that PEC0 QC would inspect the relanding of the lifted cables.
The inspector had no concerns.
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c.
The inspector observed the performance of. current diversion tests on switchgear D21. A regulated source was used to supply primary current. The secondary phase currents were verified for polarity, continuity and phase. The test. equipment was properly' calibrated.
d.
The inspector monitored the conduct of wiring connection and continuity checks on the 021 switchgear.
The field engineers yellow lined the associated electrical print to indicate wiring that was satisfactorily checked.
Lifted leads were documented.to identify the need for PECO QC reinspection.
The inspector had no concerns.
No violations were identified.
12.0 Assurance of Quality a.
As discussed in section 3e of this report, a problem involving motor operated containment isolation valves was reviewed.
The original problem was identified during Unit 1 preoperational testing when a valve which underwent instantaneous travel reversal would trip the power feed circuit. breaker. Apparently, two Reactor Water Cleanup isolation valves were retrofitted with higher rating circuit
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breakers to preclude recurrence (Startup Field Report 61A-13 and 61A-41). Based upon recent operational everts, Bechtel is performing a generic review of both Unit 1 and Unit 2 motor operated isolation valve circuits.
This open item was presented for NRC closure while the Bechtel investigations were ongoing.
The licensee has committed to better coordinate open Bechtel Quality findings with NRC open item packages that are presented for closure to pravent the premature submittal of NRC open item packages in the future.
b.
The Bechtel assumption of RPV cleanliness responsibilities resulted in a temporary degradation of control as discussed in section 6 of this report. While QC had identified the adverse conditions, the situation was not corrected in a timely manner due to a delay in processing the nonconformance documentation.
The QC organization was apparently the bottleneck to achieving timely correction of the problems because engineering disposition had not been provided to cover the RPV top holes.
The degradation of cleanliness controls appears to be attributable to the following:
General Electric did not review and approve the elements of Bechtel construction procedure CP-C-4 that related to RPV cleanliness; several concerns were documented on an NCR when an Inprocess Rework Notice could have achieved more timely resolution; and long term maintenance group personnel were not forcing a timely resolution of the storage concerns.
c.
Well controlled construction system turnover walkdowns were performed as noted in section 7 of this report.
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- 13.0 Exit Meeting The NRC resident inspector discussed the issues and findings -in.this report with members of the licensee's staff on a weekly basis, and at an
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exit meeting held on January 22, 1988.
Based on discussions held with licensee representatives on January 22, 1988,'it was determined that this report does not contain information subject.to 10 CFR 2.790 restricti_ons.
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